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Name: Anderson v. Calderon
Court: US Court of Appeals
District 9 Cir
Opinion Date: 11/17/2000
Subsequent History: None
Summary

Following his arrest, and at a time by which he should already have been arraigned, Anderson confessed to a burglary and a murder. Between the time of his arrest and arraignment, there had been a seventy-six hour delay due to a holiday and other events. Nonetheless, the California Supreme Court had affirmed Anderson’s conviction for capital murder. In this federal habeas petition, Anderson then claimed that the state had violated his Fourth Amendment rights by failing to promptly arraign him. The appellate court held that although it was error to have delayed the arraignment, Anderson’s confession was not “fruit of the poisonous tree.” The confessions were voluntary and the product of untainted free will. Prior to Anderson’s confessing, he had been given a “fresh” set of warnings pursuant to Miranda v. Arizona (1966) 384 U.S. 436, and he had been lawfully detained. The confessions had no connection to the failure to arraign promptly, and there was no willful misconduct by officers to deter. Penalty phase issues are not summarized here.